For the first time in history, national and provincial building codes
are going to include energy efficiency requirements for windows and
doors.
For the first time in history, national and provincial building codes are going to include energy efficiency requirements for windows and doors. Updates to the National Building Code are due to come into effect at the end of this year that will require fenestration components to achieve certain U-values for energy efficient performance in order to be approved as part of a newly built dwelling. In provinces that adopt the NBC, these changes will immediately become part of the building code. But most provinces that make their own building codes are also moving to include energy efficiency standards. Sometimes these are similar to what the NBC will require, but often there are differences.
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| Interesting times are ahead as provinces creep closer to making energy efficiency standards the law for windows and doors. Enforcement is bound to be spotty as building inspectors learn the new codes and settle on common interpretations.
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To get the latest updates on what’s happening in various jurisdictions across the country, we talked to Jeff Baker, Fenestration Canada’s technical consultant. Baker explained that, in addition to North American Fenestration Standard labelling for air/water ingress, window and door fabricators will soon have to prove compliance with an energy efficiency standard in many jurisdictions across the country.
“NAFS (North American Fenestration Standard/Specification) requirements will roll out across the country within the next 18 to 24 months,” he notes. “Two years ago, most of the provinces adopted the 2010 code that includes NAFS requirements, but when the national energy code comes into play, new energy ‘proof of requirements’ will also have to be met.”
Some of the NAFS requirements for entry doors have been delayed in Ontario and Nova Scotia, but Baker says they will come on line around the start of 2013. “Right now, inspectors are looking for A440 2000 test reports on entry doors, and if they dig a little deeper, they could be looking for a Canadian General Standards Board test report,” he explains. “It’s been in the code for 20 years, and usually not enforced at all, but they are starting to look at it in Ontario.”
Where National Building Code energy performance specifications take effect, all fenestration products will need a temporary label spelling out the energy performance numbers to either CSA A440.2 or National Fenestration Rating Council standards. “If you’re using NFRC, the best way of proving compliance for the energy rating is to be involved in the Energy Star program, which requires that the energy rating be calculated and labelled,” says Baker. “It’s also very important to have the metric number to prove compliance.”
All proof of requirements to meet code will have to be permanently marked on all products so that it is visible after installation. “That’s been in place in the A440 regulations for over 20 years,” says Baker. “However, all manufacturers are still not complying with that, mainly because it has not been well enforced anywhere in the country except parts of B.C. That needs to change.”
British Columbia
In this province, windows must comply with A440-00 under the building code. “However, the enforcement on the A440 standard is weak – some jurisdictions look it up, some don’t,” says Baker. “It’s just CGSB 82.5 and 82.1 for entry doors and sliding glass patio doors and these should be labelled.”
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| This label will get you by in most jurisdictions. Energy Star ratings for your climate zone usually meet or exceed the building code requirements. Only one problem: Energy Star is poised to drastically tighten its qualification requirements.
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With regard to energy, B.C. is unique among Canadian jurisdictions in that any product sold in the province has to meet requirements under the Energy Efficiency Act. “So, it’s not actually a matter of satisfying a building inspector, it’s a matter of satisfying a Ministry of Energy official,” notes Baker.
“However, they don’t have their own inspection regime, and instead of trying to enforce, they’ve hired a consultant to go out and talk to manufacturers and educate them on compliance.” Baker says the “safe” approach for manufacturers is to invite a Ministry consultant in to go over things and get recommendations, if they haven’t already been visited.
Alberta
Alberta still references the A440 in its code. Baker says although enforcement is rather lax with regard to labels to identify air, water, structural, screen and forced entry requirements, he recommends ensuring products are labelled. Alberta Ministry of Municipal Affairs officials confirm that the province has draft energy efficiency standards out for consultation now, with possible adoption by the end of 2012.
Saskatchewan
Saskatchewan follows the NBC “pretty much right out of the box,” according to Dan Knutson, president of the Saskatchewan Building Officials Association. Since the 2010 energy efficiency updates to the NBC have not been enacted yet, Saskatchewan building officials are not presently looking for any proof of energy efficiency in windows and doors.
Manitoba
This province has adopted the 2010 NBC and NAFS with some minor modifications. Baker says as long as the window is double-glazed with a low-E coating, a warm-edge spacer of some kind and an air gap greater than 10 millimetres, you’re in compliance right now. “They have introduced an energy code, but it is purely a visual inspection prescriptive requirement,” he explains. “No extra labelling is required.”
Ontario
When a builder submits plans to get a permit, there are energy requirements in Ontario that have to be submitted. However, it’s complicated to prove compliance because they allow trade-offs. “Window manufacturers are responsible to verify the performance level their products will meet,” says Baker. “Installers are responsible for choosing products that meet code.”
Inspectors may require an A440.2 simulation report or NFRC accredited reports that use NFRC data to have energy rating calculations done. ”You could also get a quasi-approval through reports completed by someone approved to do work at a SCC accredited simulation lab that does CSA, QAI or ITS simulations,” Baker notes. “Also, it is acceptable to prove compliance by submitting your energy rating NFRC and/or Energy Star data to Natural Resources Canada. The program will do the energy rating calculation for you based on the CSA data and they accept that as a means of proving compliance.” Baker adds, “We’re trying to get building officials to understand that this is occurring. This is a big deal, because there are a lot of manufacturers out there doing this, and if it is not understood this is a method of compliance, you run into trouble.”
Richard Stromberg of the Ontario Ministry of Municipal Affairs and Housing confirms that while labels are not absolutely required in Ontario, they will save contractors and fabricators a lot of headaches.
“Manufacturers routinely supply labels on windows and sliding glass doors regarding product ratings and the standard they were tested to,” he wrote in an e-mail. “In the absence of labels, municipal enforcement officials may request appropriate documentation to confirm compliance. The Standards Council of Canada is Canada’s national accreditation body and accredits testing agencies; the province does not provide this authorization. The reports of these accredited testing agencies are generally recognized and accepted by municipalities.”
Quebec
This province’s building code is based on the 2005 national one, which includes A440 2000. “In practice, you should have Energy Star ABC ratings on windows,” Baker notes. “They are working on an energy code right now that is very close to completion and it will be similar to what Ontario has done in terms of the performance levels.”
Maritimes
Newfoundland does not have a provincial building code. New Brunswick uses NAFS for air/water ingress and will follow the NBC for energy ratings. Nova Scotia is still reviewing NAFS. “They granted an 18-month extension on the labeling requirements that will expire around the first of 2013,” says Baker. “An energy labelling requirement is required right now in Nova Scotia.” P.E.I. automatically follows the NBC.
Territories
Baker says one of the territories follows the national codes. “Ironically, because of the extreme weather up north, you would think energy requirements would be found in one or more of the territory codes, but there is nothing,” notes Baker. “However, if it’s government-built housing, they built to specifications beyond code.”
Manufacturers take note
Overall, there is no single set of things that any window and door manufacturer can do that will ensure energy product compliance in all Canadian jurisdictions. “Of course, if you meet all requirements for an Energy Star rating in the far North, that would do it,” Baker says, “but these are not needed in southern Ontario in a high-density subdivision. Regional differences will remain.”
Window manufacturing is done regionally for this reason, but Baker says some large manufacturers produce very high-end windows for the entire North America market with different levels of performance. “It would be smart for a manufacturer to go through the Energy Star map and find out the highest water and wind load requirements would be in the entire region you want to sell into,” he says.
Baker’s new technical bulletin on energy requirements is now on the Fenestration Canada website. He may be doing a presentation at the Ontario Building Officials Association meeting in September.
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